Reconsidering Substance Over Form in PPL

4 Pages Posted: 24 Dec 2012

Date Written: December 10, 2012


The controversy surrounding PPL v Commissioner has framed the issue as one of substance versus form, accepting that the tax in question is economically equivalent to a tax on income. However, the fact that the tax is levied on the basis of average profits rather than total profits causes it to differ from conventional income taxes in important ways.

Suggested Citation

Goldin, Jacob, Reconsidering Substance Over Form in PPL (December 10, 2012). Tax Notes, 2012, Available at SSRN:

Jacob Goldin (Contact Author)

Stanford Law School ( email )

559 Nathan Abbott Way
Stanford, CA 94305-8610
United States

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